In Vela v. Marywood, 17 S.W.3d 750, 760-61 (Tex. App.--Austin 2000, pet. denied), a plaintiff mother raised the affirmative defense of fraud against a purported voluntary relinquishment of her parental rights. Id. at 760. While the Court acknowledged that fraud "is an elusive and shadowy term which has been defined in some cases as any cunning or artifice used to cheat or deceive another," the evidence before the court clearly demonstrated fraudulent conduct on the part of the defendant adoption agency. Id. Specifically, (1) the agency, because of its special relationship with the mother, owed a duty of complete disclosure; (2) the agency either made misrepresentations about the adoption process that were false or misleading or failed to disclose material facts; and (3) the mother was justified in relying on the agency's misrepresentations. Id. at 761, 763-64. On those facts, the Court held, the plaintiff could maintain an affirmative defense of fraud.